35bat Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 35bat ("the Platform", "we", "us") collects, uses, stores, and shares personal data relating to players and visitors ("you") who access or use the 35bat platform at https://35bat.vip. This Policy is incorporated by reference into the 35bat Terms & Conditions and should be read alongside them.

This Policy applies to all personal data we process, regardless of the medium through which it was collected — whether via the website, live chat, email, or any other interaction with the platform. By using 35bat you consent to the practices described in this Policy. If you do not agree, please stop using the platform and contact support to close your account.

2. What Personal Data We Collect

We collect different categories of personal data depending on the nature of your interaction with the platform. We collect only what is necessary for the specific purpose in question.

Registration and Account Data

• Mobile phone number (used as your primary account identifier and for account recovery in Bangladesh).
• Date of birth (collected to verify that you meet the minimum age requirement of 21 years).
• Full legal name and residential address (collected during KYC verification for identity confirmation and fraud prevention).
• Government-issued identity document details (such as National ID card or passport number) required for KYC compliance.

Payment and Transaction Data

• Payment method identifiers, including bKash account numbers, Nagad account numbers, Rocket wallet identifiers, Upay IDs, and masked Visa/Mastercard details, used solely to process deposits and withdrawals.
• Transaction history, including deposit amounts, withdrawal requests, bet history, and game results, retained for accounting, legal compliance, and dispute resolution purposes.
• Technical and device data collected automatically when you use the platform, including IP address, device type, operating system, browser type, and session timestamps. This data is used for security monitoring, fraud detection, and platform optimisation.

3. How We Use Your Personal Data

35bat processes your personal data only for specified, explicit, and legitimate purposes. We do not use your data in a way that is incompatible with the purposes for which it was collected. The primary purposes for which we use your data are:

• Account creation and management: to register your account, verify your identity, and maintain your account in good standing throughout your use of the platform.
• Payment processing: to securely process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain an accurate transaction record for your account.
• Responsible gaming and player protection: to monitor account activity for signs of problem gambling, enforce self-exclusion requests, apply deposit limits, and fulfil our duty of care to players in Bangladesh.
• Fraud prevention and security: to detect and prevent unauthorised access, money laundering, identity fraud, and other prohibited conduct described in the Terms & Conditions.
• Customer support and dispute resolution: to respond to your enquiries, investigate complaints, and resolve any disputes arising from your use of the platform.

4. Legal Basis for Processing

35bat processes personal data only where we have a valid legal basis to do so. The legal bases we rely on are:

Contractual Necessity

• Processing your registration data, payment details, and transaction history is necessary to perform the contract between you and 35bat — without this data, we cannot provide you with a functional account or process your deposits and withdrawals.
• Processing your support communications is necessary to respond to your enquiries and maintain the service relationship with you as a 35bat account holder.
• Processing your session and gameplay data is necessary to deliver the gaming products you have requested and to maintain the integrity of your account balance and bet history.

Legal Obligation

• We are required by applicable law to retain certain transaction records and to perform identity verification checks. Where a legal obligation requires us to collect or retain your data, this takes precedence.
• Anti-money laundering obligations require us to collect proof of identity and source of funds from players whose transaction volumes exceed defined thresholds.
• Responsible gaming regulations require us to monitor player activity and, where necessary, apply account restrictions or contact players who show signs of problem gambling behaviour.

5. Sharing Your Personal Data

35bat does not sell, rent, or trade your personal data. We share data only to the extent necessary to operate the platform and comply with legal obligations. The categories of recipients with whom we may share your data are:

• Payment processing partners, including mobile financial service providers (bKash, Nagad, Rocket, Upay) and card processors (Visa, Mastercard), who receive only the minimum payment data needed to execute transactions on your behalf.
• Game software providers (including Pragmatic Play, Evolution Gaming, Spribe, and other licensed suppliers) who operate game engines on the platform. These providers may receive your account reference and game activity data for the purpose of delivering game results and maintaining game integrity.
• KYC and identity verification service providers, who process your identity documents and verify that you satisfy the age and identity requirements described in the Terms & Conditions. These providers are bound by strict data processing agreements.
• Law enforcement or regulatory bodies, where we are compelled to disclose your data by court order, lawful governmental request, or where disclosure is necessary to protect the rights, property, or safety of 35bat, its players, or the public.

In every case where we share data with a third party, we require that third party to maintain appropriate security standards and to use your data only for the specified purpose. We do not permit our data-sharing partners to use your data for their own marketing purposes.

6. Data Retention

35bat retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and registration data is retained for the duration of your account and for a period of five years following account closure, to meet our anti-money laundering and record-keeping obligations.
• Transaction and payment records are retained for five years following each transaction, in accordance with financial record-keeping requirements.
• KYC verification documents are retained for five years following the completion of the verification process, or five years after account closure, whichever is the later date.
• Technical and device data (including IP address logs and session records) used for security and fraud detection is retained for 12 months from the date of collection, after which it is deleted or anonymised.
• Support communications are retained for 24 months from the date of the relevant interaction. Where a support communication relates to an unresolved dispute, it is retained until the dispute is fully resolved and for 12 months thereafter.

7. Cookies and Tracking Technologies

35bat uses cookies and similar tracking technologies to ensure the platform functions correctly, to remember your preferences, and to understand how players interact with the site. The following categories of cookies are used:

Essential Cookies

Essential cookies are strictly necessary for the platform to function. They manage your login session, maintain your account security state, and ensure that your game rounds and transactions are correctly associated with your account. Without these cookies the platform cannot operate. You cannot opt out of essential cookies while continuing to use the platform.

Analytics Cookies

Analytics cookies help us understand aggregate patterns in how players navigate the platform — for example, which sections are most visited and where players most often encounter difficulties. This data is used solely to improve the platform experience. Analytics cookie data is anonymised before analysis and is never used to identify individual players. You may opt out of analytics cookies by adjusting your browser settings; this will not affect platform functionality.

8. Your Data Rights

As a 35bat player, you hold the following rights in respect of your personal data. To exercise any of these rights, contact our support team via live chat. We will respond to all data rights requests within a reasonable period and at no charge to you.

• Right of access: You may request confirmation of whether we hold personal data about you and, if so, a copy of that data along with information about how it is being processed.
• Right to rectification: If personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to erasure: Subject to our legal retention obligations described in Section 6, you may request that we delete personal data we hold about you where it is no longer necessary for the purpose for which it was collected.
• Right to restriction of processing: You may ask us to restrict the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or where you have objected to processing pending verification of our legitimate grounds.
• Right to data portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to the processing of your personal data where we are relying on legitimate interests as the legal basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

9. Data Security

35bat takes the security of your personal data seriously. We implement appropriate technical and organisational security measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include SSL/TLS encryption for all data in transit, access controls restricting data access to authorised personnel only, regular security assessments of platform infrastructure, and secure storage of KYC documents with restricted access.

While we take all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. If you believe your account has been compromised, notify our support team immediately via live chat so that we can take prompt action.

10. International Data Transfers

Some of the third-party service providers with whom we share data (as described in Section 5) are located outside Bangladesh. Where your personal data is transferred to a recipient in another country, 35bat takes steps to ensure that appropriate safeguards are in place to protect your data. These safeguards may include:

• Standard contractual clauses or data processing agreements requiring the recipient to provide a level of data protection equivalent to that applied by 35bat.
• Transfers to countries or organisations that have been assessed as providing an adequate level of data protection under applicable standards.
• Where a transfer is to a payment processor (such as Visa or Mastercard), the transfer is governed by the payment network's own certified security and compliance framework (PCI-DSS).
• Where a transfer is to a game software provider, the provider is required under its licence conditions to maintain data security standards that meet or exceed industry requirements.
• Transfers strictly necessary for the execution of your payment instructions — for example, when your bKash or Nagad transaction requires communication with a payment gateway.

If you have questions about how your data is protected when transferred internationally, please contact our support team via live chat for further information.

11. Changes to This Privacy Policy

35bat reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our business practices, or the services we provide. When we make material changes, we will publish the updated Policy on this page with a revised "Last updated" date. We encourage you to review this page periodically to stay informed about how we protect your data.

Your continued use of the 35bat platform following publication of an updated Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree with any update, you must stop using the platform. You may request account closure by contacting the support team via live chat.

12. Contact and Data Requests

For any privacy-related enquiry, data subject access request, erasure request, or complaint regarding how 35bat processes your personal data, you may reach us through the following channels:

• Live chat: available 24/7 directly on the 35bat platform. This is the fastest way to reach our support team and is recommended for all urgent data requests.
• Email: for written data requests or formal complaints, you may contact us at the address below. We aim to acknowledge all email enquiries within 2 business days and to fully resolve data requests within 30 days.
• Please include your registered mobile number and a description of your request when contacting us, so that we can locate your account and respond efficiently.

35bat is committed to resolving all data-related complaints promptly and fairly. If after contacting us you remain dissatisfied with how we have handled your privacy concern, you may escalate the matter through our internal complaints procedure, details of which are available from the support team on request.

13. Email Contact

For written privacy enquiries and formal data subject requests, you may contact the 35bat data team by email. Please note that our support team via live chat remains the fastest route for all enquiries. All email addresses are displayed as plain text — they are not clickable links.

You may reach us by email at: [email protected]